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HMRC internal manual

Company Taxation Manual

HM Revenue & Customs
, see all updates

Particular topics: dividend-stripping: distributions: abnormal return: exempt bodies

Where the shares are held by an exempt body, ICTA88/S237 also operates to deny payment of tax credit on that part of the distribution which exceeds a normal return and to subject that part of the distribution and its associated tax credit to IT at the additional rate in force at the time of the distribution.